Apr. 13, 2021
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Allison Lee, Chairman (Acting) SEC Headquarters 100 F Street, NE Washington, DC 20549 (202) 551-2100 chairmanoffice@sec.gov Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 rule-comments@sec.gov Re: Comment on Potential Money Market Fund Reform Measures in President’s Working Group Report, File No. S7-01-2 Dear Chairman and Secretary: The AFR Education Fund sent a letter responding to a request for comment on regulatory options for money market funds in light of the collapse and bailout of many money market funds during the March 2020 coronavirus financial shock. The letter called for strong new regulatory steps to fix incentives that create financial instability for these products. It also questioned whether additional regulation should be extended to other types of fixed-income investment funds beyond money market funds narrowly defined, as there is evidence that these types of fund arrangements can also contribute to financial instability. Re: Letter: https://protect2.fireeye.com/v1/url?k=9890e619-c70bdefd-989002af-8621b744bf41-204a9760cc59d1c5&q=1&e=276032e7-0a03-45ce-b9f2-31388ba333ff&u=https%3A%2F%2Fourfinancialsecurity.org%2Fwp-content%2Fuploads%2F2021%2F04%2FAFR-Education-Fund-Comment-Letter-on-Money-Market-Funds.pdf Recent experience shows that the Commission should follow up on the recommendations of the President’s Working Group by instituting new reforms to money market funds that go well beyond the 2010 and 2014 changes. Any such package of reforms should include steps that directly address the fundamental incentives for run risk in this sector by incorporating minimum balance at risk or swing pricing requirements. The Commission should also consider whether such reforms should be extended to other types of funds where they might be beneficial for financial stability. Yours sincerely. Robert E. Rutkowski cc: Legislative Correspondence Team 1705 Longworth House Office Building